People v. Enot
REITERATIONFacts
The Antecedents: On July 8, 1960, in the barrio of San Jose, Municipality of Cataingan, Province of Masbate, Causiano Enot and Pablo Viñalon conspired and, by means of violence and force upon things, entered the house of Macario Conje while the family was sleeping. They forcibly opened a trunk, stole assorted clothing and a fighting cock valued at P35.00. On the occasion of the robbery, and to facilitate its commission, they attacked Macario Conje, Maximina Arreglado, Monina Conje (5 years old), and Baby Conje (7 months old) with bolos, inflicting fatal wounds that caused their instantaneous death. Santiaga Conje sustained an incise wound on her left leg, requiring 15 to 20 days of medical attendance. Procedural History: The accused, Causiano Enot and Pablo Viñalon, pleaded guilty to the charges of robbery with multiple homicide and physical injuries. The trial court, after questioning the accused to assure itself of their understanding and guilt, found them guilty beyond reasonable doubt. The court considered the aggravating circumstances of nocturnity, superior strength, cruelty, abuse of confidence, treachery, and evident premeditation, and the mitigating circumstance of a plea of guilty. They were sentenced to death. The case was elevated to the Supreme Court for automatic review. The Petition: The defendants-appellants did not question the facts but argued that the death penalty was improperly imposed, contending that the penalty should have been reclusion perpetua. They claimed the trial court erred in not considering intoxication and lack of instruction as mitigating circumstances, and in considering nocturnity and superior strength as separate aggravating circumstances from treachery, and in considering evident premeditation as an aggravating circumstance.
Issue(s)
Whether intoxication and lack of instruction can be considered mitigating circumstances in this case. Whether nocturnity and superior strength should be considered separate aggravating circumstances from treachery. Whether evident premeditation was correctly considered an aggravating circumstance. Whether the penalty of death was correctly imposed given the plea of guilty and the attendant circumstances.
Ruling
The Supreme Court affirmed the decision of the trial court, sentencing each of the accused-appellants, Causiano Enot and Pablo Viñalon, to the penalty of death for the crime of robbery with multiple homicide and physical injuries. The Court also ordered the defendants-appellants to pay jointly and severally P6,000.00 to the heirs of each of the four deceased victims.
Ratio Decidendi
On the issue of intoxication and lack of instruction as mitigating circumstances: The Court held that for intoxication to be mitigating, it must be proven that the accused were drunk to the point of losing reason and self-control during the commission of the crime. The defense failed to present sufficient evidence of intoxication, as Viñalon's confession only mentioned drinking tuba without specifying the quantity, and it was not formally offered as an exhibit. Furthermore, the benefit of lack of instruction is not applicable to crimes of theft or robbery, and certainly not to homicide, as it is universally known that such acts are inherently wrong and unlawful. On the issue of nocturnity and superior strength as aggravating circumstances: The Court ruled that nocturnity should not have been considered a separate aggravating circumstance from treachery, as nighttime is often part of the treacherous means employed to insure the execution of the crime. However, the use of superior strength and disregard for the sex and age of the victims were properly considered aggravating circumstances, especially given that most victims were defenseless women and children. On the issue of evident premeditation: The Court affirmed that evident premeditation was a valid aggravating circumstance. This was established by the fact that the accused had previously conspired to rob the house and had planned to assault the occupants if necessary to accomplish their purpose, demonstrating a clear and deliberate intent. On the imposition of the death penalty: The Court found that the crime of robbery with multiple homicide and physical injuries was aggravated by treachery, the use of superior strength, disregard of the sex and age of the victims, evident premeditation, and dwelling. While the plea of guilty is a mitigating circumstance, it was outweighed by the numerous aggravating circumstances and the senseless depravity with which the offense was committed, including the hacking of a baby's head. Therefore, the death sentence imposed by the trial court was affirmed.
Main Doctrine
A plea of guilty, while a mitigating circumstance, does not automatically warrant a reduction of penalty when the crime committed is robbery with multiple homicide and physical injuries, especially when attended by numerous aggravating circumstances. The penalty of death may still be imposed.